ML20010F875

Responses to Joint Intervenors Second Set of Interrogatories.Affidavits & Certificate of Svc Encl

ML20010F875
Person / Time
Site:	Callaway
Issue date:	09/10/1981
From:	Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	JOINT INTERVENORS - CALLAWAY
References
NUDOCS 8109150062
Download: ML20010F875 (11)

Text

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09/10/81 UNITED STATES OF AMERICA I R, NUCLEAR REGULATORY COMMISSI6L L

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARt}

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In the Matter of

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Docket Nos. STN '501483

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STN 50 W (Callaway Plant, Units 1 and 2)

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ANSWERS OF THE NRC STAFF TO JOINT INTERVENORS SECOND SET OF INTERROGATORIES The NRC Staff herewith files its responses to Joint Intervenors Second Set of Interrogatories.

1.

The FSAR section referenced in response to Question 2, First Set of Interrogatories (FSAR section 3.8.3.6.4,3) will be revievred by the NRC Staff as a mat *er of course in conjunction with the OL Safety Evaluation Review pursuant to the requirennents of 10 C.F.R. 5 50.34(b) _et. seq.

t 2.

HRC inspectors thoroughly reviewed audits of Cives Steel Co. on August 10, 1981 while r,1eeting with Union Electric in St. Louis as part of the review of the embedded plate report.

3.

Source:

Visual inspection by the NRC Staff with subsequent measurement by Applicant. While a description of such a crack is outlined in detail in NCR-2-2081-C-A, and.vhile tt.e maximum width of same has been noted and retained, the number that Applicant gave,*e crack using Appli-cant's numbering system has not been retained by the NRC Staf f, due, in part, to the hairline nature of such cracks.

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[ 4.

The NRC's requirements for reportability are delineated in 10 C.F.R. 9 50.55(e). That regulation does not make the same distinction suggested in the interrogatory.. The distinction in the NRC regulations of 50.55(e) is whether or not a defect is significant, that if left uncorrected wou" adversely effect the plant operation.

5.

Your reference to Joint Intervenors First Set of Interrogatories should be numbers 58 and 59, not 68 and 69 as stated in the interrogatory.

This item is to be closed in inspection report 81-20 which is to be issued shortly.

i 6.

(a) The Staff stated that the list was "su'ostantia'ily complete.'

Applicant listed NCR-1683-C-A although the Staff did not.

The aforemen-tioned NCR was originated after Pour No. 2C231WO3 was completed. That NCR was not listed by the Staff because it originated after the aforemen-tioned pour was completed.

NCR-2-1042-C-A which was listed by the Applicant could be added to the Staff list inasmuch as the subject matter of that report, while not 4

relating solely to the third lift, did pertain, in part, to the third lift. That NCR was discussed in detail in the subsequent I&E investiga-tion report. Questions pertaining to Applicant's list or produced NCR's should be addressed to that party.

(b) See " Objections of the NRC Staff to Joint Intervenors' Second Set of Interrogatories." HCR-1532-C-B could also be added to the Staff list. The subject matter of tne NCR, however, should not-have constituted i

a " hold" on the pour because the noncor. forming item was not erected to become part of the pour.

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E 3-(c) The " statement of Completed Action" requires written sign-l off by supervisory personnel which can take place well-after the action was completed. This may be especially true on minor or ir.significant items where the overall corrective process is satisfactory.

(d) Approximately 4:00 p.m., returning approximately 8:00 a.m.

the next day.

The Staff is aware of no such evaluation records.

As to the last part of the question, the Staff did not believe that any such NCR's would remain uncorrected and an informal Staff review of such NCRs did l

not indicate any signi. icant matters which would adversely effect the safety of the plant.

7.

As to whether Mr. Smart was present, see " Objections of the L'RC Staff to Joint Intervenors' Second Set of Interrogatories."

(a)

The complete contents of the investigation and interviews with ironworkers and other site personnel are contained in NRC inspection report 77-11, transmitted to tne Applicant on February 24, 1978.

(b)

The NRC Staff did discuss with the Permittee matters re-garding the specification code requirements relative to reinforcing steel placement as discussed throughout NRC inspection report 77-11 ar.d 78-01.

(c)

Discussion of this item is contained in reports 77-11 and 78-01 including enclosure 1.

8.

The vertical and horizontal reinforcing steel are physically tied together, however, the concrete cover is measured to the horizontal steel which was designed and placed on the outside of the vertical steel.

9.

Details regarding the observed placement of reinforcing steel are described in NRC inspection report 78-01, and enclosure 1 thereto.

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10.

(a)

Yes, during the NRC inspection conducted on January 3-6, 1978.

(b)

See " Objections of the NRC Staff to Joint Intervenors' Second Set of Interrogatories."

(c)

This information is contained in NRC inspection reports 77-11 and 78-01.

(d)

See " Objections of the NRC Staff to Joint Intervenors' Second Set af Interrogatories."

(e)

Discussions with Applicant were neld regarding reinforcing steel and is documented in NRC reports 77-11 and 78-01.

(f)

Yes.

(g)

See " Objections of the NRC Staff to Joint Intervenors' Second Set of Interrogatories."

11. (a)-(c) Supplement 11 entitled " Severity Categories," which delineates and describes Severity V violations as well as the other cate-gories was published in 45 Fed. Reg. 66758-59 (October 7) is attat.hed hereto.

12. (a) A Region IV inspection was conducted from April 23-25, 1980.

The NRC Staff also reviewed a SNUPPS audit of Gulf-Western concerning this matter.

(b) 10 C.F.R. 5s 50.55(e)(3)(4) permits the Staff to evaluate the adequacy of the responsive or corrective actions taken by the Licensee with respect to Licensee-reported items. That regulation does not however require the Staff to determine whether a violation would othenvise exist in the context of a non-Licensee reported item under 10 C.F.R. Part 60.

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(c).See " Objections of the' NRC -Staff to Joint Intervenors Second i

Set of Interrogatcries."

(d)

(1) Region IV transmitted letter to Taylor Forge, Gulf-Western j

(6/11/80)'for [ Region IV Inspection] Report #99900704/80-01, i

(2)

Letter from N. Petrick (SNUPPS) to B. Grier, Region I, SLNRC79-20 (11/29/79).

13.

See attached affidavits. The undersigned NRC. Staff counsel and

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the Project manager, Gordon Edison, are routinely involved in such responses.

Attorney Making Objections, j

P,0y P. Lessy Counsel for NRC Staff I

Dated at Bethesda, Maryland 4

this 10th day of September,1981.

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Rules Fesizrn! Register / Vol. 45, 160. 198 / Ta*aday. October 7.1860 /

f;h able to pesiana lh in* dad functiza exsrdses judgroest and di /km in under cerestaaaaAhans (such as not f.ccordar:ce with the criteria described wning the seeestry inval of the operable unisse effsita power is deter f

in sections IV.B and IV.tl ebove. Examples of enfortement settoes that enforcement sanctions. Including the 3.Re: ease of radioactivity effsite violasons and the appropdate available):

(could)(will normaDy)be taken foi decision to tmpose a civil penalty and samsta than the Technu-at Specification Severity Irre! L E or El violations are the sImeant of such penalty, sensistant hmit*: or set forth inTable 2.* The actual with the general principles of this a violatlan of to CFd $ase such that pro;;tession to be used in a partienlarstatement of pokey and the Wral an amendment was not sought.

rits of the case.

D. Severtty IV-Violstions involving:

case wul depend on the circumstances.

me.Ite Commission willbe provided

1. h= adequate review or the failure to Totde th c(W c/M-

• 1. N * *"' N

• written notification of all enforsement make a review in accordance with to a,:tions invdving dv0 penaltias or CRt 33.3 or 3D CRt 2L that does not

3*'"' d#"'M"' " ** 8" h orders.De Commission will be result in a severity level L E or DJ consulted pior to taking enfarasment violation:.

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- action in the following situations (unless

2. Any heense limit,not covend by

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- the urgency of the situation dictate..

Severity Lewin L E cw IIL being as

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(1) An action affechas facility

3. Failure to meet require 2nents not

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.. operations that requires balandag the casered in Severity Isvels L E or HL a

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that measureably degrades the safety of publichealth and safety and ammon, defense and secudty tmpheations operations, incident response, or the e

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• • " * ".".*,"i*1I,*4,L. """ ""'.*".%,2 operating the facility with the poten a. radiological or other hazards as

4. FaDure to make a required Licensee n ss====

environment or

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Event Report when the nported matter with facihty oper'stion: ".. c a

(2) Proposals to impose dril penaltiesitself does not constitute a violation.

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. ir. amounts greater than the maximum E. Severity V--Other violations, sucl.

Normany the propession of values set forth in =rhan IV.B; as failun to follow proceduren, that enfor-et actions far repetitwe (3) Any pnW enforcament schon have other than minor safety or violations will be based on violationswhich the twaalan asks to be environments ' significanu.

consulted on: or F. Severity VI-Violations that have under a single lfcense. When more than one facility is covered by a single (4) Any action e JEica' Director minor safety or environmental Lcense, the nc: mal p%.e rir. ion will be believes warranis >=="de aigmficance.

based on repetitive vicriations et an involvement.

Sappisemat Mver cata, individual facihty and not on repetitive SupplemmotN4 %

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r Facility Canstructiort Iowe i b d be

atunda, Racetor Operazions A.Severit[1-iolations trivolving all some ctrcumstane=e: e.g., where there is A. Severity 1-Violations involving-or part of a straffture or system that is common contr:1 over some facet ofL A Safety IJmit. as d=fmad in the carnpleted in auch a manner that it f:cility operations: repetitive vialahn"*

may be cha21ed even though the second TechnicalSpe@=h= being would not have antisfied tra intended

'm-safety nlatedftspose.

yceeded:

< vislation occurred at a different facihty 2. A systsm designed to prevent or

& Seven ' D4ciatima invohing:

and/or under a diCuent hcease.Formitigate a aseious safety eeent not being cant' deficiency in quality

, example, a physical security violation at abla u pericemits intended safety LA assumnos propsm implementdon Unit 2 of a dual unit plant that repests funcean when acasany eaHed upon to related to more than one work activity an earher violation at Unit 1 adghtbe 4

structural, piping. electncal vaaric

3. An so5 dental crin==Wy: er

! (e.g,datione;. a. shown by muitipre,,

considend wpetitive. ^.~

o fc.n 4.Reimase ar d-citetty on.ite program Isaplementation violations that l

l V.u. pr==Mties The Director. OHice of Wan and greaterthsn tea (1al thans tha Teolmical were e at trianMned and conected until Specinea6an hadt.'R.Sermity D-Vidaties levolving:

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. Enfomarnant, as the prindpal inspection by the quahty assurance enforcement officer of the a.aa""-

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L Asystem designed to prevent or quality control check points that are has been dalagated the antharity to

• mitigate serious safety events not belnd lasse notices of violations, civil able to performits intendedsafety l

retted upon to identify such violahana-l penalaies, and ordera.58 Da Dimetor

2. All or part d a struceam or system i

go.,u n I 8'E3 ***I% *E*I'*

that le completed in such a==nnar that L '""""" "See (10 times the Technica I

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4g ag C.Sewertry 1E-Viataha involving-)

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C. SeverVy ID-Violations involving:

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=The nw=== st te omes.atsommi emammar "s.d "$7,,",,*$@mn**ar*

Canditim for Openedon being anseeded L tack of assurance program ted to a single work

@he e irm=nsd est==r-mI =. arm.

to Amn== Stat =nar4 g,,p ementmean g

structural. piping whase the app I actreity sce==s====ary h ** nn.amad *=,=taa h=hh

& A syssam deslanadtoprevent er le or Ermndations) as shownby

'twer.

esserur by NER andfees.S b %

was. net

== asps. preeram implementation

""d "'"' """* **"T. '*h*'s t 'hian= af.d".M, 8minisato a seriana salaty event notbelas l

viola $as that were not identified and k

errected bF mare than one quauty E O.=a.or

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acnonabased an.entausesret ammans assurance /quauty control checkpoint Adswnwo nma has beam emissued na==6=*r to me,as- -r.,prws

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.r Federal Register / Vol. 45. No.196 / TwAay. October 7.1980 / Proposed Rules

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2. Preoprenticoal het program

1. Fainsre to provide protection or

3. Release of radioactive material to implementation la wasch the violations control of acxzes into the protected area: an unrestricted area in excess of 5 tismes nsdt in falLng to emfina the design

2. Failure to previde protection or the limits of to CFR 20.10e; control of amess t, a vital ana or

4. Failure to make an tsamediate safety mW.-oss of the structure o f material access ana:

andfication as required by 10 CFR rystem: or

3. Failure to provide protection or 2n403(a)(i) and to Cm 20.403(a)(2).

3. Failun to Qa required to Cm control of access ao tha transport vehicle.

5. A radiation levelin an unrestncted 50.55{e) repC 1 D. Seve(ty IV-Violations involving or the SNM being transported; or arm that exmeds 80 milbrem/ hour for a L FailmWElow one or more

4. FaDure to estrbhsh or ma6tain one ho.tr period; a '.eguards systems dealgned or used to 6 Disposal oflicensed matenaiin Quahty Assurana Cdtsris not d r.*ct the unauthorized removal of

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amounting to Severity level L E. or m Category D SNM Irom arese of 5 times the limits of to CFR 20.303'or vio&ations; or.

2. landaquate review or 2he failure to authorized use or storage.

M; or

• anale a review in acxmidanc-with 10 D. Severity IV-Violations involving-

7. Exposure of a worker in restricted L Fauure to estah!ish or main *ain anos in emaa d 5 umes the hmits d m CFR Part 22A F. Severi V--Other violations. such safeguards systems designed or Cm 2am3.

as faihne to proceer a, th6t employed to detect the smauthorned C. Severity ID-Violations involving have other than minc s(f:ty or i removal of Category E SNM from area,

1. Exposure of a worker to levels in

. enn:v=m w tagmnrane,.

} of authorized use or storage:

excess of those p *=d in to Cm L Failure of 'he secu:ity organazation F. Severof VI-Violations that have 20.101 or 20.104:

minor safstNMvuvemental to follow procedures to cepe with to:tual

2. A rediationlevelin an unrestdcted security inddents that are not covend area that exceeds 5 millinm/ hour for a

4nifien, by Severity levels 1. H. or m; Supfitamant IR.-Sevedty Categories

3. Failure of corporate or site security one hour period:

3. Failure to make a 24-hour management to provide adequate nodSca&n as aquimd by M 3 I_ Scleguard,^

&ncen m sup si n de secznity A. Severity bViolatiocs involving program eat do at M in SnerW 2a6 m an h& ate noMScahn

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1. Actual entry of an unauthorized 14 =1L H. m m W a r a requimd by M CR 2nga) inividualinto a vital ana or material

' Inadequate revie-or the falhar to 4.Sebstantial potential for an access area frnm outside the p otected make a nem in accmdance we M axposm m n! ease in excess d 2 Cm 20 where such u% or relesse doc 5 area that was undetected at the time of C3 Part 2L F. Severity V-Obar violations, such not occur (e.g, entry into high radiation

2. detual theft, loss. or drve sion of as failure t lo w procadas or an area without having performed an spedal nudear material (SNM) or an act approve s*curhy phn 64t have other adequate servey. operation of a rediaden facihty with a nonchning of radiological sabo

, or 6an mina safeguards =""'","

3Jailure to report an actual F. Severity VWViolations that have interlock system):

5. Release of raCoactive matedal to or atten:pted theft or dryersion sf SNM anina safeguards s.

or an act of radiological sabotage.

an umestricted area in excess of the

. B. Severty B--Violations involving-SupplemmetIV. *.m%

Categories i

L Breakdown of security systems g,,33 p3}.si.cz 2 CF# Purt 20 EL Disposal oflicensed material not designed or used to prevent any A. Severity WViolationeinvolving:

covered S Severity Levels I or H:

unasthorned individual from entering a-L Exposure of a workerin==== of

7. Exposure of a workerin reatricted vkal aree ce mateMal access ares from 25 rems of radiation to the whoe body.'

area.s in excess of the limits of 10 CFR outside the protected area such that 150 rens to the akin of the whole body.

2a103:or access codd have been gained without or 375 reens to the feet, ankles, M oc

8. Release for unrestricted u'se of fonarms:

contaminated material or equipment detection.

2. Fallare to operate the central (or

2. Exposan of a ma==har of Abe peiblic substanhany in==a. of NRC or secondary) alarm station:

in excess of 0.5 r. as of radiation:

Ec=nse limits ce the failure to

3. Failure to respond to unenthortred

3. Rafaa as of radioactive snatarial to de aM==hte plant m as ree!nd, or unantidpated security alarm an uwestncied area in excess of 2 D. Severity IV-Violations involving:

a-mdations.

s tims the limits of to CFR 20.100' L FaHm to idlo* "Iuirements ('+

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4. FaDure to establish or maintain

4. A radiation level in an unrestdcted b

saf tems demsned or 20 minarsam/ hour tw an ax dan t

not emp to prevent o'r detect the covered in Severity Imvels L IL or HL unauthorized removal of CetegoryI E. Disposal dlicensed matedalin dat sukannah redeces the margm of am fan anos dan 6M use w nanHtiaa er ana=*ations in -aaa of 2

es t!'e hafts of10 Cm 20.303 or radiationlevella en unrestricted down of transportsbon ure of's workar in restricted area such that an ladtvidaal may receive

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d areas in excess of to times the limits of gnatar than 2 milhren in a one bour 8.

Sm.t or acts d neological sabotage.

Penod se 100 smahrem la av seven

. to CR 20.103.

consec tive days; C.Severny EbVideocos g~,'

B. Severity D-Violations involving.

3. FaDure to make a 30 day L Exposure of a worker in==== of 5 DotiSCation required by 30 CFR 20.405; e.1.

rems or todiatled to the whole body. 30 mere sien is i d emvity di ships.,peopsraast md a reme to the skin of the whole body, or 75

4. Inadegrale review or fathee to ce anw pecramang wn n6 imm.d 6.

,,m, g,ih, g,g, aa hands, or make a rvview in accordance with w

@g '"*'"."".C'$

1 Exposure of a==mher of the public Cm Part 2L

. forearms.

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.ier b.mm e, An===a sf 0.1 ausma of rom =s'aa E. Severtty V-Vlotatices involutag-c

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J UNITED STATES OF AMt.RICA NUCLEAR REGULATORY COMMISSION B_EFORL THE ATOMIC SAFETY AND LICENSING BOARD, In the Matter of

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UNION ELECTRIC COMPANY

)

Docket Nos. STN 50-483

)

STN 50-486 (Callaway Plant, l' nits 1 and 2)

)

i AFFIDAVIT CF EUGENE J. GALLAGHER Now comes Eugene J. Gallagher, and being duly sworn, deposes and says as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as Senior Civil Enuinear, Office of Inspection and Enforcement, Reactor Engineering Branch, Mechanical, Structural and Metallurgical Section, Division of Resident and Regional Reactor Inspection.

2.

I am duly authorized to answer Questions 1,2,3,4,5,7,8, 9,10, and 11 and I hereby certify that the answer given is true to the best of qy knowledge.

Eug6he J allagher(l Subscribed and sworn to before me this {% day of fh,1981.

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My Commission expires:

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s' UNITED STATES OF AMERICA NUCLEAR REGULATORY CONMTSSTON BEFORE TIIE ATOMTC '5AYETY ~ AND LICENSLMC BOARD, In the Matter of

)

)

UNTON ELECTRTC COMPANY

)

Ducket Nos. STN 50-483

)

SIN 5'3-486 (Callaway Plant, Units I and 2

)

AyFTDAVTT,OF JAMES E. FOSTER rbw comes James E. Voster, nnd hning duly sworn, deposes and says as follnwn:

1.

I am employed by the U. S. Nuclear Ragulatory Conmiission as Tnvancigator Riti.

2.

I am du.'.y nuthc.rized to answer Questions 6,10, and 11 and I hereby certify that the answer given is true to the best of ay knowledge.

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,,,Jhads E. Foster Subscribed and sworn to before me thin 10th day of September, 1981.

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My Conninuiun expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

UNION ELECTRIC COMPANY

)

Docket Nos. STN 50-483

)

STN 50-486 (Callaway Plant, Units 1 and 2)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " ANSWERS OF THE NRC STAFF TO JOINT INTERytNORS SECOND SET OF INTERROGATORIES" in the above-captioned r

proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal cail system, this 10th day of September,1981.

James P. Gleason, Esq., Chi ruan Administrative Judge Barbara Shull l

Atomic Safety and Licensing Board Lenore iceb 513 Gilmoure Drive League of Women Voters of Missouri j

Silver Spring, MD 20901 2138 Wootscn Road St. Louis, MO 63114 Mr. Glenn O. Bright

• Administrative Judge Atomic Safety and Licensing Board Marjorie Reilly U.S. Nuclear Regulatory Commission Energy Chairman of the League of Washington, DC 20555 Women Voters of Univ. City, M0 7065 Pershing Avenue Dr. Jerry R. Kline*

University City, MO 63130 Administrative Jt;dge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Gerald Charnoff, Esq.

Wdshington, DC 20555 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 4

M. John G. Reed 1800 M Street, N.W.

Rt. 1 Washington, DC 20036 Kingdom City, MO 65262 Dan I. Bolef Treva J. Hearne President, Board of Directors Assistant General Counsel for the Coalition for the Environment, Missouri Public Service Commission St. Louis Region P.O. Box 360 6267 Delmar Boulevard Jefferson City, MD 65101 University City, MO 63130

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.. Donald Bollinger, Member Rose Levering, Member Missourians for Safe Energy Crawdad Alliance 6267 Delmar Boulevard 7370a Dale Avenue University City, MO 63130 St. Louis, MO 63117 Mr. Fred Luekey Kenneth M. Chackes Presiding Judge, Montgomery County Chackes and Hoare Rural Route Attorney for Joint Intervenors Rhineland, MO 65069 314 N. Broadway t

St. Louis, Missouri 63102 Mayor Howard Steffen Chamois, MO 65024 Professor Wiiliam H. Miller Mr. Earl Brown Missouri Kansas Section, School District Superintendent American c' ear Society P.O. Box 9

' apartment of Nuclear Engineering Kingdom City, MO 65262

' J26 Engineering Building University of Missouri Mr. Samuel J. Birk Columbia, FO 65211 R.R. #1, Box 243 Morrison, MO 650(,1 Mr. Harold Lottman Presiding Judge, Dasconade County Rober6 G. Wright Rt. 1 Associate Judge, Eastern District Owensville, MO 65066 County Court, Callaway County, Missouri Eric A. Eisen, Esq.

Route #1 Birch, Horton, Bittner and Monroe Fulton, MO 65251 Suite 1100 1140 Connecticut Avenue, it.W.

Atonic Safety and Licensing Washington, DC 2003C Board Panel

• U.S. Nuclear Regulatory Comission Docketing and Service Section*

Washington, DC 20555 Office of the Secretary U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Washington, DC 20555 Appeal Board

• U.S. Nuclear Regulatory Comission Washington, DC 20555

/q Roy P. LessyU i

Deputy Assistant Chief Hearing Counsel

-